Privacy Policy

1.1 Important information and who we are

‍Welcome to Nuggit’s Privacy Policy (“Privacy Policy”). Nuggit is the trading name of The Digital Content Group Ltd (“we”, “us”, or “our”), a company registered in England and Wales under Company Registration Number 13978278 with its registered office at 64 Southwark Bridge Road, London, SE1 0AS, United Kingdom. We are registered as a Data Controller with the Information Commissioners Office under reference number ZB506325.

We act as agent for a company, Digital Licence UK Limited (the “Principal”) and have authority to enter contracts on behalf of our Principal. Therefore, where we mention the provision of our services or products in this Privacy Policy, this includes the provision of services or products by our Principal where we have assisted with putting in place the contract for those services or products.

We are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation, the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe, through your use of this website, when you contact us with an enquiry about our services and in connection with our services or products. The Privacy Policy will tell you about your privacy rights and how the law protects you. The individuals from which we may gather and use data can include:

• Customers and users (including prospective customers and users)
• Suppliers
• Business contacts
• Third parties connected to the customers (for example customer’s agent or manager)

and any otherpeople that we have a relationship with or may need to contact.

This Privacy Policy applies to all Personal Data processed at any time by us.

1.2 Your Data Controller

The Digital Content Group Ltd is the Data Controller and responsible for your Personal Data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact us using the details set out below:

• Email: info@go-nuggit.com
• Postal address: 64 Southwark Bridge Road, London, SE1 0AS, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2.1 Types of data we collect about you

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Identity Data: This includes first name, last name, channel ID, pseudonym, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: This includes your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us, and our third parties and your communications preferences.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Financial Data: These are your banking details e.g. your account number and sort code.
• Transactional Data: This is information of details and records of all payments you have made for our services or products.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.
  
• Social Media Performance Data: the performance of digital content on social media platforms which is linked to a specific Channel ID or Pseudonym. This data may include views, sources, RPM, revenue, and other analytics.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 How we collect your Personal Data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services, create an account on our website, request marketing to be sent to you or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

Social Media Performance Data from the following parties:

• We may use API Services of platforms we work with (including YouTube API Services) to collect performance data.  We recommend that you review the privacy policies and your personal privacy settings on any social media platform where our services appear to ensure that those privacy policies and your personal privacy settings accurately reflect your consent for the use of any Personal Data. You can refer to the Google Privacy Policy through this link.  

YouTube and Google User Data:

• We may use a Google Outh Access Token that you authorise to authenticate your YouTube Account ownership and access your Google Sensitive Scope Information  
• YouTube Channel and Video performance data from your YouTube Account– to value and track performance of your YouTube Library assets. This data may include views, sources, RPM, revenue, and other analytics. The use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.  
• Technical Data from analytics providers such as Google;
• Contact, Financial and Transactional Data from providers of technical, payment and delivery services.

2.3 The lawful bases for using your Personal Data

There are a number of legal grounds under UK privacy laws that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent certain situations such as before sending you email newsletters and before sending third party direct marketing communications to you via email. You have the right to withdraw consent to our marketing at any time by contacting us.
• “Contractual Obligations”: Where we require certain information from you in order to fulfil our, or our Principal’s, contractual obligations with you and provide you with the promised service.
• “Legal Compliance”: Where we need to comply with a legal obligation, such as reporting fraudulent activity or other illegal actions.
• “Legitimate Interest”: Where we need to collect certain information from you to be able to meet our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests

3.1 Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

3.2 Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers maybe relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased (or expressed an interest in) services or products from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

If you have given your opt-in consent to us sharing your personal data with third parties for their own purposes, we have no control over what those third parties do with your personal data after you have given such consent. You should contact the relevant third party to opt-out of any communications, or exercise any of your data subject rights in relation to such third party.

You may with draw your consent to our sharing your personal data with third parties for their own purposes at any time by contacting us (see section 1.2 above). However, this will not apply to any personal data already shared with any third party on the basis of the opt-in consent you had previously given.

Where you opt out of receiving marketing messages from us, this will not apply to personal data provided to us as a result of a product/service purchase.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.1 Your legal rights

‍Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.2 below for more details on how you can make a data subject access request.
• Right to rectification. You have a right to request correction of the personal data that we hold about you.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
• Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data.

Note that this is not an absolute right and it only applies in certain circumstances, for example:

• Where we are processing your personal data for direct marketing purposes.
• Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances.

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it asyou need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whetherwe have overriding legitimate grounds to use it.

• Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you wish to make a request under any of these rights, please contact us at info@go-nuggit.com
• Right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you with draw your consent, we may not be able to provide certain products or services to you.We will advise you if this is the case at the time you withdraw your consent.

4.2 Data Subject Access Requests

You will not generally have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request or alternatively we may charge a reasonable fee.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

5.1 Sharing your data with third parties

We may share your Personal Data with the parties set out below:

• Digital Licence UK Limited, our Principal, acting as an independent controller, to the extent required for it to enter and perform any contract with you.
• Service providers, acting as processors, who provide IT and administration services,
• Professional advisers, acting as processors, who provide consultancy, legal and accounting services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or licence our technology. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
• Lawyers, or law enforcement bodies, to the extent required for legal reasons in order to enforce our terms and conditions or this Privacy Policy.
• With your opt-in consent, any third party companies who we deal with from time to time, or who may get in touch with us, who want to contact you for their own purposes. Such third party companies will act as independent controllers, and will not be processors of Nuggit.

Any disclosure to any third party acting as our processor will be subject to confidentiality and security obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.